In its press release of 30 April 2019, the Dutch Central Bank (De Nederlandsche Bank, DNB) emphasises that financial institutions are required to take measures to identify and assess money laundering and terrorist financing risks in accordance with the recently revised Act on the prevention of money laundering and terrorist financing (Wet ter voorkoming van witwassen en financieren van terrorisme, Wwft).

DNB is actively monitoring financial institutions to ensure that they comply with their obligations under the Wwft, which includes the obligation to draw up a risk analysis relating to money laundering and terrorist financing. DNB notes that:

  • it expects that this analysis forms an integral part of the financial institution’s systematic integrity risk analysis;
  • Dutch branch offices of foreign banks also comply with this obligation; and
  • the revised Wwft requires financial institutions to have one daily policymaker who is ultimately responsible for compliance with the Wwft (DNB is investigating how this requirement is being complied with in practice).

DNB is working on a revised version of its guidance document on the Wwft and Dutch sanctions legislation and expects to publish this for consultation shortly.

View DNB’s press release (Dutch only), 30 April 2019.

View DNB’s current guidance document on the Wwft and Dutch sanctions legislation.